Guidance for medicine developers and companies on COVID-19

The European Medicines Agency (EMA) is providing guidance for medicine developers and pharmaceutical companies to help speed up medicine and vaccine development and approval for COVID-19, and on how they should address the regulatory challenges arising from the COVID-19 pandemic. 

Early support for medicine and vaccine developers

EMA encourages developers of potential vaccines or treatments for COVID-19 to contact EMA as soon as possible to discuss their strategy for evidence-generation.

They should email their proposals to 2019-ncov@ema.europa.eu.

Depending on the maturity of development, EMA will set up initial discussions on suitable mechanisms to fast-track development and approval, with priority given to the most relevant proposals.

Establishing contact early in the development process is important for ensuring that developers can submit well-prepared applications and make use of the accelerated procedures EMA has put in place for COVID-19 treatments and vaccines.

Accelerated procedures for COVID-19 treatments and vaccines

Guidance is available for developers of potential COVID-19 treatments and vaccines on the rapid review procedures EMA has put in place to speed up development and approval:

These rapid procedures can accelerate every step of the regulatory pathway while ensuring that robust evidence on efficacy, safety and quality is generated to support scientific and regulatory decisions.

They are available for initial marketing authorisation applications and extension applications for authorised medicines that are being repurposed for the treatment of COVID-19.

Overview of rapid procedures

PROCEDUREFEATURES
Rapid scientific advice
  • Free of charge (in accordance with the PDF icondecision of EMA’s Executive Director )
  • No pre-specified submission deadlines
  • Review is reduced to a maximum of 20 days (from 40-70 days)
  • Flexibility on type and extent of briefing dossier, agreed on a case-by-case basis
Rapid agreement of paediatric investigation plans (PIPs) and rapid compliance check
  • No pre-specified submission deadlines 
  • Review of a PIP is reduced to a minimum of 20 days (from 120 days). Exact timeline depends on complexity of PIP and the preparedness by the sponsor to respond to questions
  • EMA decision following a review is reduced to 2 days (from 10 days)
  • Possibility for developer to provide a focused scientific documentation, agreed on a case-by-case basis
  • Compliance check can be reduced to 4 days if necessary 
Rolling review
  • EMA's Committee for Medicinal Products for Human Use (CHMP) reviews data as they become available on a rolling basis, while development is still ongoing
  • Several rolling review cycles can be carried out during the evaluation of one product as data continue to emerge, with each cycle lasting around two weeks depending on the amount of data to be assessed
  • Each submission occurs in eCTD format with an application form, a Module 2 overview and responses to a cumulative listing of all outstanding questions from previous review cycles
  • Once the data package is complete, the developer submits a formal marketing authorisation application which is then processed under a shortened timetable
Accelerated assessment
  • Can be considered for medicines and vaccines not undergoing a rolling review
  • Review is reduced to 150 days (from 210 days) or less after validation of a complete application

 

EMA is ready to apply further flexibility, where it is established that shortening of any other procedural step could have an important public-health impact in dealing with the COVID-19 pandemic.

In addition, EMA will substantially accelerate the linguistic review process for procedures related to COVID-19.

It will also keep the European Commission informed about COVID-19-related applications to help speed up decisions on authorisations.

Other development-support and early-access mechanisms

Medicine and vaccine developers may also consider other regulatory mechanisms to receive enhanced support during medicine or vaccine development, or to enable early patient access to potential treatments or vaccines, including:

Advice for sponsors and stakeholders involved in clinical trials for COVID-19 treatments and vaccines

EMA's Committee for Medicinal Products for Human Use (CHMP) is urging the EU research community to pritoritise large randomised controlled clinical studies as these are most likely to generate the conclusive evidence needed to enable rapid development and approval of potential COVID-19 treatments. The CHMP also emphasises the need to include all EU countries in these trials:

Update: In line with the CHMP's statement, members of EMA staff and its scientific committees provided recommendations on concrete actions that stakeholders involved in COVID-19 clinical trials should take to enable the conduct of decision-relevant clinical trials, in an article published on 15 May 2020:

Advice to sponsors of COVID-19 clinical trials in the EU is in included in the guidance on clinical trial management during the pandemic:

EMA is currently engaging with stakeholders who can further support the conduct of COVID-19 clinical trials across Europe.

For information on ongoing COVID-19 clinical trials in the EU, see Treatments and vaccines for COVID-19: Information on ongoing clinical trials in the EU.

Advice for stakeholders involved in COVID-19-related observational studies

Update: EMA is encouraging collaboration between researchers on high-quality, multi-centre observational studies in the context of COVID-19, and transparency about study protocols and results.

High-quality observational research of real-world data can complement the results of randomised clinical trials in providing evidence on the safety and effectiveness of vaccines and treatments for COVID-19. Such research is also critical for understanding how exposure to certain medicines can affect the risk or the severity of COVID-19.

Researchers should adhere to existing guidelines on the appropriate design and conduct of pharmacoepidemiological studies in order to generate reliable and reproduceable evidence, including the Guide on methodological standards in pharmacoepidemiology developed by the European Network of Centres for Pharmacoepidemiology and Pharmacovigilance (ENCePP).

To facilitate collaboration between researchers and to help improve the size and methodological rigour of studies, ENCePP has set up a dedicated COVID-19 response group. For more information on the group's activities, see its mandate on the ENCePP website.

In addition, recommendations on conducting high-quality research during the pandemic are available in an article published by EMA staff and EU researchers on 5 May 2020:

EMA and ENCePP are encouraging researchers to register their pharmacoepidemiological studies (and make study protocols and reports public) in the European Union electronic register of post-authorisation studies (EU PAS Register). They should include ‘COVID-19’ in the study title to allow easy retrieval of their studies.

Advice for sponsors of clinical trials affected by the pandemic

Guidance is available for clinical-trial sponsors on how they should adjust the management of clinical trials and participants during the COVID-19 pandemic. This covers concrete changes and protocol deviations for dealing with extraordinary situations, such as the need for isolating participants, limited access to public spaces and the reallocation of healthcare professionals:

Update: An update to this guidance on 28 April 2020 provided additional flexibility and clarification on:

  • the distribution of medicines to trial participants. This takes into account social-distancing measures and possible limitations in trial site and hospital resources;
  • the remote verification of source data (SDV) in the context of social distancing measures. This aims to facilitate activities that support the approval of COVID-19 and other life-saving medicines;
  • notifying authorities of urgent actions taken to protect trial participants against an immediate hazard, or of other changes taken to support patient safety or data robustness.

Guidance is also available on the actions that sponsors of affected clinical trials should take to help ensure the integrity of their studies and the interpretation of the study results while safeguarding the safety of trial participants as a first priority:

In line with this guidance, EMA will be flexible and pragmatic during the assessment of affected clinical trial data submitted to the Agency as part of marketing authorisation applications.

Guidance on regulatory expectations and flexibility (human medicines)

Guidance is available for companies responsible for human medicines on adaptations to the regulatory framework to address challenges arising from the COVID-19 pandemic, with a particular focus on crucial medicines for use in COVID-19 patients:

The guidance covers:

Companies should note that some of the measures described in the guidance are reserved for crucial medicines used for treating COVID-19 patients.

The guidance was agreed by EMA, the European Commission, the European medicines regulatory network and endorsed by the EU Executive Steering Group on Shortages of Medicines Caused by Major Events

Additional guidance is available for marketing authorisation holders on submitting COVID-19-related ICSRs to EudraVigilance, including on the correct use of COVID-19-related terms of version 23.0 of the Medical Dictionary for Regulatory Activities (MedDRA):

Guidance on regulatory expectations and flexibility (veterinary medicines)

Guidance is available for companies responsible for veterinary medicines on adaptations to the regulatory framework to address challenges arising from the COVID-19 pandemic:

The guidance covers:

The guidance was agreed by EMA, the European Commission, the European medicines regulatory network and endorsed by the EU Executive Steering Group on Shortages of Medicines Caused by Major Events. It was first published on 30 April 2020.

Further updates to this guidance are possible and likely as the pandemic develops.

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